January 12, 2015 – The National Association of State Credit Union Supervisors (NASCUS) submitted its comment letter today to the Federal Housing Finance Agency (FHFA) on its proposal to amend its regulations governing Federal Home Loan Bank (FHLB).

FHFA’s proposal would extend application requirements for members to hold 1%, and in some cases 10%, of their assets in residential mortgage loans to an ongoing membership requirement. FHFA also proposes excluding “captive insurers” from membership. (A NASCUS summary of the proposal is available here.)

In their letter, NASCUS urged FHFA to reconsider the proposed changes to FHLB membership, noting their concern “that the rule as written runs contrary to prevailing supervisory concerns regarding interest rate risk (IRR) and may diminish available liquidity for some credit unions.”